The Commissioners for HM Revenue and Customs v Invercylde Property Renovation LLP and Clackmannanshire Regeneration LLP: [2020] UKUT 0161 (TCC)

Upper Tribunal Tax and Chancery decision of Lord Tyre and Judge Raghavan on 27 May 2020.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 27 May 2020

• Category: Tax
• Release date: 27 May 2020

Read the full decision in The Commissioners for HM Revenue and Customs v Invercylde Property Renovation LLP and Clackmannanshire Regeneration LLP: [2020] UKUT 0161 (TCC) .

INCOME TAX –– limited liability partnerships – Income Tax (Trading and Other Income) Act 2005, section 863 – whether HMRC had power to open enquiry under Taxes Management Act 1970, section 12AC – whether any enquiry should have been made under Finance Act 1998, Schedule 18, paragraph 24 – whether closure notices issued under Taxes Management Act 1970, section 28B were valid – yes – appeal allowed.

Published 27 May 2020